Asbestos Management Procedure

Transcription

1 Document Control Revision No. Date Document Reviewed Publication on Web Site Date of next Review Summary of main changes 1 March 2016 October 2016 o Conversion from Policy to Procedure o Checked for legal compliance o Minor changes to update terminology or to reflect current practices 2 October 2016 October 2017 o Version approved at FMD H&S Meeting 24/10/2016

2 Contents 1 Introduction Accountabilities General Figure 1 Organisation/Responsibility chart..5 3 Asbestos What is asbestos? Risk associated with asbestos. 6 4 Asbestos Assessment Surveys Surveying and bulk sampling competence Asbestos register Auditing of the asbestos register Risk assessment. 8 5 Asbestos Management Introduction Actions University refurbishment/demolition works Asbestos management plan Asbestos management procedures Project management for all construction works including embedded spaces.11 6 Monitoring and Review Re-inspections Record keeping Reviews Information, Instruction and Training Introduction Works performed by outside contractors Acquisition, Demolition and Disposal of Premises Acquisition Disposal Demolition Waste Disposal Exposure to Suspect or Damaged Asbestos Flow Chart October 2016

3 10.1. General Exposure to Suspect or Damaged Asbestos Flow Chart Use of Licenced Asbestos Removal Contractors (LARC) Qualifications.16 Key for Appendix Floor Charts..16 Appendix A Emergency Response Flow Chart Stage Appendix A Emergency Response Flow Chart Stage Appendix B Project Works Flow Chart Stage Appendix B Project Works Flow Chart - Stage 2 (ACMs Identified)...20 Appendix C Maintenance and Reactive Works Flow Chart. 21 Appendix D Summary of Construction Work Definitions Appendix E Verification Form..23 October 2016

4 1 Introduction 1.1 Objective recognises the responsibilities and duties placed on the University under the Control of Asbestos Regulations As the Dutyholder of the premise, is responsible for managing asbestos containing materials to ensure the health and safety of all staff, students, building occupiers, contractors and others. The aim of the University is to have a building portfolio which is fully safe from asbestos containing materials. It may not be possible to remove all asbestos containing materials (ACMs) as they may be part of the building structure however the University will ensure that ACMs are maintained in a good condition and not disturbed. The University has a structured, risk-based approach to the management and control of ACMs within the property portfolio to reduce the risk to its lowest practical level. Accredited asbestos analytical, surveying and removal contractors will be used for all asbestos works as necessary. The University recognises the hazard of asbestos and the risks to health that it poses. Therefore, to fulfil its moral, social and legal obligations, an asbestos management plan has been developed and is being implemented to ensure that ACMs are kept in good condition and a risk based systematic process is followed. This includes re-inspection surveys being carried out and any actions added to the asbestos management plan. This Procedure details the health and safety arrangements that the University has in place to comply with the overall University Safety, Health and Wellbeing Policy and all relevant health and safety legislation including the Health and Safety at Work etc. Act 1974 and Control of Asbestos Regulations Asbestos specific guidance documents and Approved Codes of Practices shall also be consulted in order to fulfil statutory obligations including HSG 247, 248 and

5 2 Accountabilities 2.1 General will appoint suitably qualified and competent staff to discharge its responsibilities regarding asbestos. The following identifies the responsibilities for asbestos management throughout the University. This Asbestos Management Plan (AMP) is designed in such a way to integrate into the existing Glasgow Caledonian University construction and maintenance/operations programmes. The following key personnel are, under Regulation 4 of the Control of Asbestos Regulations 2012 (Duty to Manage Asbestos in non-domestic premises), responsible for the implementation of the control measures discussed in this document: DUTYHOLDER Principal Chief Financial Officer & VP Infrastructure, Finance and Infrastructure Director of Estates Estates Manager RESPONSIBILITY The University commitment to promoting a healthy and safe working environment. Allocate funding for AMP. Overall responsibility for the Directorate and is responsible for the overall asbestos management strategy including procedures and practices. Ensuring development and implementation of this Asbestos Management Procedure and AMP. Acts on behalf of the Director of Estates in respect of this Asbestos Management Procedure. Evaluate on an annual basis, or more frequently as required, the need to hold asbestos awareness and refresher training for any employees that manage and/or work near known or suspect ACMs. Assist the Safety and Compliance Officer in respect of their duties under the Day-to-day management of the Safety and Compliance Officer Project management. Assist, by the provision of information, individual designers or project managers in the evaluation of any maintenance, renovation or construction activities in respect of the presence of ACMs. Identification and dissemination of information to appropriate staff following discovery any suspect material. Ensure all contractors working on asbestos are aware of and meet the requirements of the. Ensure project personnel (including contractors) are inducted. Instruction of any asbestos works. 2

6 Safety and Compliance Officer Commissioning and implementing the AMP. The day-to-day administration and maintenance of the AMP. Monitor the implementation of the AMP. Commission or otherwise complete a detailed and comprehensive asbestos register for all buildings suspected of containing ACMs. This includes for any future acquisitions. Maintenance of the Asbestos Register and all other relevant information pertaining to the control and management of asbestos. Co-ordinate the response to any report of suspect ACMs, asbestos debris, damage or disturbance. This will include evaluation of circumstances under which it has been encountered and initiating the necessary sampling, clean-up, removal or repair as appropriate liaising with the Estates Manager who will be responsible for final approval. Provide detailed technical specifications (including the surveying and air monitoring services) for scheduled or emergency abatement works. Commission or otherwise complete a regular review and evaluation of all ACMs once per year or more frequently as circumstances and assessments warrant. Provide final approval for all asbestos work requisitions forwarded for their attention. Critically review all management processes and their effectiveness as well as the overall progress made against the AMP. Advise managers and project managers on the retrieval and evaluation of information within asbestos registers and any additional asbestos surveys required for any maintenance or refurbishment activities that are being planned. Monitor asbestos work instructions/method statements to ensure the individual manager or project manager in charge of the work has followed this and update the asbestos register accordingly. Ensure that completion paperwork and all necessary air monitoring certificates are available to those that require this information. Ensure that all original and subsequent asbestos survey information is available. Report to the Estates Manager any defects or non-compliances relating to the asbestos removal Contractor s performance, including suitability of work areas, adherence to method statement and compliance with University procedures. 3

7 Ensuring that any works that may disturb or damage ACMs are avoided. Contractors/Directly Employed Labour (DEL)/All Employees of the University Report to the Estates Manager any suspect material discovered and if any has been damaged or disturbed where staff/contractors are likely to undertake work that may affect such materials. Removal of asbestos containing pipework gaskets in emergency situations by nominated trained Directly Employed Labour (DEL) only. As and when required: Asbestos Surveying and Analytical Contractor Licensed Asbestos Removal Contractor (LARC) Undertaking surveys and sampling, where requested, in accordance with current legislation. Checking areas on completion of works to ensure that the LARC has completed their scope of works and all affected areas have been left in a satisfactory condition. Issuing survey reports and air testing certificates to meet the standards of HSG 264 and 248 Bringing to the attention of the Estates Manager and/or the Safety and Compliance Officer any asbestos concerns on University Premises. Complying with current legislation, ACOPs and guidance including HSG 247 Removal and/or encapsulation of ACMs in a safe and controlled manner without increasing risk of exposure to asbestos fibre to staff, students and visitors etc. Attend site for the making safe of any uncontrolled disturbances of ACMs. Liaise with Asbestos Analyst to complete works as per HSG 248. University Health and Safety Advisor Liaise with University Duty holders above as necessary. 4

8 2.2 Figure 1 Organisation/Responsibility Chart Key Information/ Consultation Management Instruction/ Management University Health and Safety Advisor Monitor/audit the effectiveness of the Asbestos Management Plan University Responsible for approval and overall implementation of the Asbestos Management Plan Director of Estates Responsible for the overall strategic asbestos management and Asbestos Management Plan Estates Manager Acts on behalf of the Director of Estates and Facilities in respect of the Asbestos Management plan Trade Union & Safety Representatives Consultation through agreed channels on matters affecting employees they represent Maintenance Staff, Contractors, Building Managers, Heads of University/Dept and Employees Ensure that any works that may disturb or damage ACMs are avoided. Report any suspect/suspected asbestos to the Safety and Compliance officer. Safety and Compliance Officer Day-to-day administration and maintenance of the Asbestos Management programme Managed by Estates Manager Local Estates Managers, Project Managers, Project Leaders Follow University asbestos management procedures for planned maintenance, projects and emergency/out-ofhours discovery Analytical and Air monitoring Contractor Analysis and air monitoring as required (UKAS accredited) Asbestos Removal Contractor Controlled licensed removal of asbestos Asbestos Surveying Contractor Asbestos surveys and sampling 5

9 3 Asbestos 3.1 What is Asbestos? Asbestos is a naturally occurring fibrous material with unique properties that make it ideal for reinforcing many materials used in the manufacturing of building products. Used throughout the construction of public, commercial and industrial buildings, it is used as an insulator, has good fire protection properties and protects against corrosion. Asbestos is often mixed with other materials, so it can be difficult to know whether it is present without carrying out specialised surveys. However, buildings which were built before the year 2000 are likely to contain asbestos somewhere within the premises and it can be found in: Ceiling and floor tiles Lagging used on pipes and boilers Sprayed and textured coatings Insulating board Gaskets and seals There are three main types of asbestos Chrysotile (white) Amosite (brown) Crocidolite (blue) All asbestos types are dangerous carcinogens but brown and blue are more hazardous than white. It should be remembered that the colour itself is not a reliable indication of the type of asbestos, since the natural colour tends to change through age and reaction to heat. Analysis of samples within a laboratory is the only way to confirm the type of asbestos. 3.2 Risks Associated with Asbestos Asbestos is only a risk to human health if asbestos fibres are released into the air and breathed into the lungs. Breathing in air containing asbestos fibres can lead to asbestos-related diseases, mainly cancers of the lungs and chest lining. There is usually a long delay between first exposure to asbestos and the onset of disease. This can vary from 15 to 60 years. There is no cure for asbestos-related diseases. The presence of asbestos within buildings does not, in itself, present a hazard since the asbestos is likely to be mixed with other substances and sealed with paint or encapsulated (enclosed) by other materials. Surveys show that asbestos in good condition does not release hazardous fibres, unless it is subjected to disturbance or damage. Therefore the risk of exposure to breathable fibres from asbestos found in normal circumstances is low. It is generally safer, especially where asbestos is located in a position which is out of reach, to contain the asbestos materials in situ; since there can often be a greater hazard created by removal. Containment of asbestos is achieved by sealing, painting and physical encapsulation. Where damage to ACMs is found the area must be locked down and remedial treatment carried out including removal where necessary. All asbestos remedial works will be carried out by a specialist contractor. 6

10 4 Asbestos Assessment 4.1 Surveys Asbestos surveys are carried out for the University by a specialised contractor with qualified asbestos surveyors carrying out these surveys. These are produced in report format to the University in order to meet the scope of the works requested within the order. The survey will determine the location, form, type and condition of all suspected/confirmed ACMs as per the areas within the scope of works. The type of survey/inspection undertaken will be appropriate for the circumstances. There are two survey types in accordance with HSE Guidance Document: HSG264, Asbestos The Survey Guide for the surveying, sampling and assessment of asbestos containing materials. Management Survey Sampling, identification and assessment survey The management survey is carried out to locate, as far as reasonably practicable, the presence and extent of any suspect ACMs in the building. This is to ensure that no one is harmed by the continuing presence of asbestos in the premises during normal occupation and use of the premise i.e. ACMs remain in good condition and are not inadvertently disturbed during maintenance, general use and other works. Minor intrusive work may be required. Refurbishment/Demolition survey Full access sampling and identification survey (pre-demolition/major refurbishment works) This type of survey is designed to be used as a basis for tendering for the removal of ACMs from buildings before demolition or major refurbishment, by locating and describing, as far as reasonably practicable, all ACMs in the building. This will involve destructive inspection as necessary to gain access, including gaining access to difficult to reach areas. A full sampling programme is undertaken to identify possible ACMs and estimate the volume and surface area of ACMs. Although different types of surveys can be specified and used depending on the circumstances, it is important that the building owner, employer and the surveyor knows exactly which type of survey is to be carried out, what the specifications for each type are and in which areas they are to be used. The type of survey must conform to HSG 264, otherwise interpretation of the survey reports will be difficult and the management plan produced may not adequately minimize the risks involved. It is possible that at larger premises a mixture of survey types will be appropriate e.g. a boiler house due for demolition will require a Refurbishment/demolition survey, while other parts of the premises require a Management Survey. Therefore it is important that there is a clear statement and record of the types of surveys that are to be carried out, including the reasons for the type selected, where they are to be carried out and an estimate of the number of samples to be collected. It is vitally important to provide a clear scope of works to the surveyor so that the survey covers the areas of the refurbishment works. Any changes to the scope of works being carried out for the refurbishment may require a further asbestos refurbishment/demolition survey to be carried out. There are instances where differing types of asbestos surveys are carried out within a building. Again, it is important that the asbestos information covers the areas required for works being carried out. 4.2 Surveying and Bulk Sampling Competence Both management and refurbishment/demolition surveys require the removal of samples to identify the presence of asbestos content within the material. The only way to confirm asbestos content is to have the sample analysed under controlled conditions. There may be some instances where a suspicious material is discovered and directed sampling of the material is required by the surveyor rather than a full survey carried out. Asbestos samples must be sent to a laboratory for analysis. The University will only use accredited surveyors for asbestos surveys, which includes the collection of bulk samples. HSG 264 and HSG 248 provide details for suitable sampling and analysis strategy and must be followed by the contractors. 7

11 Any laboratory to which bulk samples are sent for testing must be accredited by UKAS for the relevant testing method. Analytical laboratories must hold Category 1 laboratory status in the Regular Inter-laboratory Counting Exchanges (RICE) scheme and have a satisfactory performance in the Asbestos in Materials Scheme (AIMS) scheme. Only UKAS accredited analysts will be used for analytical services following the completion of asbestos remedial or removal works. Works must be in accordance with HSG Asbestos Register The asbestos register forms an up-to-date record of all ACMs within any given location or property within the University. Details of any asbestos removal works will be clearly recorded in the asbestos register. The register should also contain information about materials that are suspected or presumed to contain asbestos but that have not been accessed or sampled for confirmatory analysis. Any areas or items not accessed must also be recorded and presumed to contain asbestos unless there is strong evidence to prove otherwise. The asbestos register is available in electronic format with a hard copy located in the Security Office. The Safety and Compliance Officer is responsible for updating the asbestos register. Unless otherwise stated, the asbestos register only contains those ACMs that are reasonably accessible and does not include ACMs that may be hidden within the fabric of the building or in inaccessible areas. Further investigation must be carried out for these areas in the form of a refurbishment survey. A verification form must be signed upon reading the asbestos register to confirm that the work areas have been checked within the asbestos register prior to beginning works. This is available with the hard copy of the asbestos register. An example of this is available in appendix E. 4.4 Auditing of Asbestos Register Regular audits will be undertaken to ensure the asbestos register is kept up to date. The audit will comprise of a walk through visual re-inspection by the Safety and Compliance Officer or asbestos surveying contractor. The audit frequency will depend on the type and condition of the ACMs but will not be less than an annual inspection. The Safety and Compliance Officer will ensure that the previous asbestos re-inspection survey indicates the audit frequency. The audit frequency will be agreed between the Estates Manager and Safety and Compliance Officer. 4.5 Risk Assessment A risk assessment will be carried out for all ACMs and reviewed at regular intervals. The risk assessment will follow the algorithm set out in HSG 264 (Asbestos: The Survey Guide) which provides a material assessment of the ACM (ie the condition of the asbestos) and a priority assessment (ie the environment it is within). These two aspects will bring together the overall risk assessment score of the ACM. The material assessment looks at four key areas. These are: Product Type Damage Surface Treatment Asbestos Type The material assessment looks purely at the ACM to assess the overall condition of the ACM. Each aspect contributes to the overall material score. The priority assessment looks at four further areas in relation to the area of the asbestos. These are: Maintenance activity; Occupant activity; Likelihood of disturbance Human exposure potential 8

12 These areas are essential to assess whether the ACM is influenced by the environmental that it is in. This is because it can be within a high footfall area which increases the potential for fibre release or the area may require access readily for maintenance meaning it is of higher risk of being disturbed. An algorithm score is produced from the four main areas to provide the result of the priority assessment. The overall risk assessment is the combination of the material and priority assessment and this will form the control measures that are required for the ACMs. Detailed knowledge of the use of the buildings is required to ensure that accurate priority assessments are completed. The results of the risk assessment will determine the action plans that are required. The maximum algorithm score from the combined material and priority assessment is 24. The combined risk assessment score will determine the action to be taken as per the asbestos scoring system. These scores can be broken down into categories with actions assigned depending on the score. The asbestos scoring is as follows. Asbestos Scoring System - Scale of Risk High Medium Low Very Low HIGH RISK MATERIAL REQUIRING URGENT ATTENTION = Score 18 or more The potential hazard arising from this category warrants urgent attention. Immediate plans for consultation between the Estates Manager, Safety and Compliance Officer and Asbestos Contractors should be made for the remediation of the ACMs, appropriate action to be agreed according to location and condition. The option chosen for remediation will follow the hierarchy of control. In most cases it shall be necessary to prevent access or occupation until remediation has been agreed and completed. MEDIUM RISK MATERIAL REQUIRING PROGRAMMED REMOVAL WITHIN A SPECIFIED TIMESCALE/INSPECTION = Score 14 to 17 This category indicates that deterioration in any of the contributory factors may result in asbestos fibre release. Therefore all asbestos, within this category, would typically warrant remediation on a programmed basis usually within a specified time scale, appropriate action to be agreed with the Estates Manager according to location and condition. The option chosen for remediation will follow the hierarchy of control. LOW RISK MATERIAL REQUIRING REGULAR INSPECTION/REMOVAL AS PART OF REFURBISHMENT AND DEMOLITION PROJECTS = Score 9 to 13 This category indicates the need for regular monitoring as situations within this category do not pose an imminent risk to health and likelihood of fibre release is low under existing conditions but, this risk may rapidly alter should any number of factors contribute to the materials deterioration. It is recommended that ACMs falling into this category is visually inspected on an annual basis to ascertain any change in condition and if any does, it can be promptly subject to control actions to prevent and increase in exposure and uncontrolled fibre release and a reclassification to the above category. Any remedial action identified through reclassification to a high category is to be agreed with the Estates Manager according to location and condition. The option chosen for remediation will follow the hierarchy of control. VERY LOW RISK MATERIAL REQUIRING ANNUAL INSPECTION/REMOVAL AS PART OF REFURBISHMENT AND DEMOLITION PROJECTS = Score less than or equal to 8 This category indicates low priority. ACMs within this category should be subject to annual visual inspection to ascertain any change in condition or when usage of the area changes. Where such a change occurs, prioritisation to a higher risk category may be necessary. NONE 0 POINTS No action necessary 9

13 5 Asbestos Management 5.1 Introduction is responsible for managing ACMs to ensure the health and safety of all staff, students, building occupiers, contractors and all other stakeholders. It is important that ACMs are either removed or maintained in good condition so that the risk of asbestos fibres being released is minimal. In order to comply with the Control of Asbestos Regulations 2012, an asbestos management plan has been produced to ensure the continued safe occupation and operation of University premises. 5.2 Actions The asbestos management plan will detail the actions that are required for ACMs based on the outcome of the risk assessment. Various aspects will be considered when implementing an action as it may not be possible to remove the ACM depending on the area/construction of the material. The following actions will be considered: Monitor the condition of ACMs: The material is in good condition and unlikely to be disturbed during normal occupation and use of the premise. The condition of the ACMs will be monitored regularly and results recorded. The minimum period of re-inspection will be annually. Encapsulate or Seal ACMs: The material is showing slight signs of damage therefore a protective coating can be applied to the ACM to inhibit the release of asbestos fibres. Enclosure: The material is showing slight signs of damage. A barrier is placed between the accessible area and the ACM to protect the ACM from damage. This may be in the form of plywood. If barriers are installed they must be on a monitoring regime and categorised as either permanent or temporary. Temporary barriers must be inspected weekly and must only be installed for a maximum of six months. Removal: The material is showing signs of deterioration or at risk of being disturbed therefore removal should be considered. Material must be removed under controlled conditions which is dependent on the type and location of the ACM. 5.3 University Refurbishment/Demolition Works An asbestos project review must be completed prior to any planned refurbishment or demolition works taking place. It is the responsibility of the Project Manager for the works to ensure that the form is completed and forwarded to the Estates Manager as soon as the works are planned. The requirement for refurbishment/demolition surveys or asbestos removal works must be considered in relation to the project. The availability to remove ACMs should always be considered as this will remove the risk and also ongoing costs associated with re-inspection surveys. Asbestos removal works will be undertaken by a licensed asbestos removal contractor. The only exception is the removal of asbestos containing pipework gaskets in emergency situations. These may be removed by nominated directly employed labour. All of these works must comply with all aspects of the Environmental Protection Act 1990 as amended or superseded, and in particular, must ensure that all waste arising from the work is removed to a licensed disposal point using registered carriers. Further, a transfer note system must be operated in order that the disposal of waste is adequately documented to prove compliance with the Act. All work with ACMs shall be carried out in accordance with the approved codes of practice associated with the Control of Asbestos Regulations 2012 together with the provisions of the Health and Safety at Work etc. Act 1974 and all other relevant legislation. Section 10 of this document contains procedures that must be followed in the event of exposure to suspected, unidentified or damaged ACMs. 10

14 5.4 Asbestos Management Plan A separate Asbestos Management Plan has been produced for the University based upon the actions identified within the asbestos re-inspection surveys. Any ACMs that are identified as requiring actions will be timetabled for action according to their risk assessment. These actions will be subject to regular review. 5.5 s The flow charts in Appendices A to C outline University Management Procedures for Planned Maintenance, Project works and Out of Hours/Emergency situations. 5.6 Project Management for all Construction Works Including Embedded Spaces All Project Managers/Estates Personnel involved in construction works must review the works with regard to: the possible presence of asbestos, control of the works to ensure appropriate measures are taken to avoid damage or exposure of ACMs, necessary remedial or removal works (based on the ultimate long term aim of asbestos safe/free working environment) and the impact of any remedial asbestos works on the project programme. Project Managers/Estate Personnel must seek assistance from the Maintenance Manager regarding the Asbestos Register and involvement of the Safety and Compliance Officer at the earliest planning stages of a project. Project Managers/Estate Personnel must include information on the presence or otherwise of asbestos in pre-construction information as required by CDM All refurbishment projects including those in embedded spaces must undergo the above review which will, unless agreed with the University s competent person and recorded in writing; include a refurbishment or demolition survey. 11

15 6 Monitoring and Review 6.1 Re-inspections Asbestos re-inspection surveys will be carried out by an asbestos surveying contractor that is accredited by UKAS (United Kingdom Accreditation Service). These will be carried out on an annual basis or at shorter intervals depending on the result of the risk assessment. The re-inspection survey will consist of a visual assessment of the condition of the ACMs and will be updated in line with the risk assessment as per the algorithm set out in HSG 264. A further assessment will be carried out for the priority aspect of the algorithm to form the overall risk assessment. The overall risk assessment will be updated following this re-inspection survey and any new actions will be added to the asbestos management plan. The asbestos register will also be updated as necessary. It is not normal practice to require re-sampling of materials during a re-inspection survey. However, if unidentified or undocumented suspect materials are discovered during the re-inspection survey these will be sampled and analysed as required. The asbestos register will be updated and re-issued as necessary. 6.2 Record Keeping Estates Department shall maintain detailed records of all activities relating to asbestos works which have been undertaken within and on premises. The records kept shall include: Records marked with a (*) must be retained for a minimum of 40 years Copies of all asbestos survey reports, including updates and amendments;* Site induction records pertaining to the informing of contractors about the presence of asbestos on site, and that such contractors have been appropriately trained in safe work procedures and practices; Records pertaining to the informing of employees about the presence of asbestos on site, and that such employees have been appropriately trained in safe work procedures and practices; Records of any asbestos abatement works performed on site;* Clearance certificates indicating areas are safe to reoccupy after asbestos abatement works;* Asbestos fibre air monitoring results.* Records of management plan reviews. Accident and near miss records will be sent to hsforms@gcu.ac.uk, the University Health and Safety Advisor and the Safety and Compliance Officer. The University shall incorporate asbestos issues into building work contracts to ensure any ACMs are appropriately controlled or removed. 6.3 Review The asbestos register will be updated following any changes identified in the re-inspection survey or if any actions have been carried out. The asbestos management plan is a separate document and will also be updated at this point to reflect any of these changes that have been identified. The re-inspection survey will detail the frequency of future re-inspections but as a minimum these will be annually. Audits of the asbestos register, re-inspection surveys and asbestos management plan will be undertaken at random intervals by the Estates Manager and/or the Health and Safety advisor if necessary. A review of all asbestos registers and procedures will be carried out annually or following any changes in legislation or approved codes of practices. A review will also be carried out, if necessary, following any asbestos incidents. 12

16 7 Information, Instruction and Training 6.1 Asbestos Awareness Training Appropriate information, instruction and training will be provided for all employees who are likely to work around or manage ACMs, including their supervisors. All contractors working on behalf of the University must have up to date asbestos awareness training if there is the potential for them to be working around ACMs. The asbestos awareness training will take the form of a face to face training session that shall cover general awareness of asbestos and the procedures in place within the University to manage asbestos. This includes reinspection surveys, asbestos management plan and emergency procedures to follow if suspect asbestos is discovered. Each training session is individually tailored to address the needs of the group being trained and is mandatory. Asbestos awareness training will be carried out on an annual basis that will be reviewed as necessary to comply with Regulation 10 of the Control of Asbestos Regulations The content of the asbestos awareness training shall cover the following areas, but not limited to: Properties of asbestos Effects on health Types, use and likely location of asbestos General emergency asbestos procedures Avoiding risk of asbestos GCU management of asbestos 6.2 Works Performed by Outside Contractors Whenever an outside contractor is to be engaged to perform construction work (as defined in appendix D) on University premises, the individual manager or project manager assigned to the work shall obtain confirmation that the Contractor s workforce has received appropriate asbestos training. Any works on confirmed or suspected ACMs will be carried out by a licenced asbestos removal contractor. Only contractors that can meet or exceed the requirements set out in Section 11 of this procedure document will be used for asbestos remedial or removal works. 13

17 8 Acquisition, Demolition and Disposal of Premises 8.1 Acquisition When premises are surveyed with a view to the University acquiring them, the survey is to incorporate a statement regarding the availability of an up-to-date Asbestos Register and the extent, location and type of any ACMs in the premises. If there is any doubt in the standard or accuracy of the asbestos register/asbestos surveys, an asbestos survey must be commissioned. The survey must be carried out by a competent person as detailed in section 4.2 of this document. 8.2 Disposal Where premises are being sold or transferred, the Director of Estates must ensure that the person responsible for the disposal of the premises has been informed of the location and extent of any known ACMs on the premises, the limitations of the surveys undertaken and the location of the current asbestos register. 8.3 Demolition An asbestos refurbishment/demolition survey must be commissioned to identify any ACMs within the property prior to demolition. The Project Manager, in liaison with the Estates Manager, must then assess the risks of asbestos removal prior to demolition in accordance with the Control of Asbestos Regulations 2012 and remove In accordance with HSG Waste Disposal All waste that contains asbestos will be disposed of under the Hazardous Waste Regulations; Scotland - The Special Waste Regulations 1996; The Special Waste Amendment (Scotland) Regulation 2004; The Waste (Scotland) Regulations 2012 A licensed carrier will transfer asbestos waste to a licensed waste disposal site or holding facility. Copies of the completed consignment note following disposal must be requested from the contractor and kept on file. 14

18 10 Exposure to Suspect or Damaged Asbestos Flow Chart 10.1 General The following procedure must be followed in the event that any asbestos or suspect ACMs are encountered, damaged or otherwise disturbed e.g. during routine maintenance, construction, etc Exposure to Suspect or Damaged Asbestos Flow Chart Discover or damage materials that could contain asbestos? STOP WORK IMMEDIATELY Leave and close/lock the area and keep all persons out DO NOT REMOVE ANY TOOLS, EQUIPMENT OR MATERIALS If there is dust or debris on hair, skin or clothing, wipe down with damp rags and shower as soon as possible. Put up warning sign POSSIBLE ASBESTOS HAZARD KEEP OUT Notify Line Manager immediately who will contact Estates Manager via phone call Estates Manager will arrange for inspection and samples/air tests to be carried out by the specialist contractor Results will confirm if asbestos is present Removal works will be arranged by Estates Manager if necessary and access allowed following removals and air testing Incident reporting and investigation Record within asbestos register Refer to Appendix A and Estates and Facilities Standard Operating Procedures for more detail. 15

19 11 Use of Licenced Asbestos Removal Contractors (LARC) 11.1 Qualifications The University will only use LARCs for asbestos removal or remediation works at any University owned or occupied premises. The contractor must be able to demonstrate compliance with the following requirements to ensure the safety of all stakeholders within the University and that a high standard of work is completed. Contractor must hold a valid HSE license (ASLIC) to comply with the Asbestos (Licensing) Regulations Both the firm as well as the supervisory staff must have a minimum of three (3) years prior experience in the field of asbestos control and remediation. All supervisory staff must hold a recognised certificate proving attendance at an asbestos removal training course (2 day minimum duration) and have performed supervisory functions on at least five (5) other asbestos abatement projects of similar size and complexity. The firm must carry and/or be able to provide Professional Indemnity Insurance endorsed specifically to provide coverage in respect of any claim arising from the exposure, clean-up, removal, containment, testing or monitoring of asbestos. The said policy must provide coverage in an amount not less than one (1) million pounds ( 1,000,000) per occurrence and must also be issued on an occurrence-based form. Additionally, the policy must provide coverage for public, product and pollution liability insurance of not less than five (5) million pounds ( 5,000,000) and employer liability insurance of not less than ten (10) million pounds ( 10,000,000). Be licensed to transport asbestos waste and/or demonstrate that sufficient arrangements have been secured with a licensed waste haulier to ensure proper handling and final disposal of all waste at a licensed landfill site. Provide proof that all operatives are suitably trained, competent and experienced to carry out asbestos removal and remediation works. Provide proof that all employees are enrolled in a medial surveillance programme and have valid face fit tests for their respirators. KEYS FOR APPENDICES FLOW CHARTS Lines key Abbreviations key Information Action LARC Licensed Asbestos Removal contractor Action positive ACMs ACMs Asbestos Containing Materials Action negative ACMs NAD No Asbestos Detected Colour Key University staff/managers Non-University staff/managers Estates Department Asbestos Contractors 16

20 APPENDIX A EMERGENCY RESPONSE FLOW CHART EMERGENCY RESPONSE STAGE 1 DISCOVERY OR ACCIDENTAL DAMAGE OF SUSPECT ACM STOP WORK VACATE AREA MAKE AREA SAFE/LOCK OFF IF POSSIBLE If there is dust or debris on hair, skin or clothing, wipe down with damp rags and shower as soon as possible. UNIVERSITY CONTRACTOR REPORT TO LINE MANAGER ARE YOU UNIVERSITY OR A CONTRACTOR? REPORT TO YOUR MANAGER WORKS INSTRUCTED BY CAMPUS TEAM FOR PROJECTS MANAGER CONTACTS THE SAFETY AND COMPLIANCE OFFICER ASAP BY PHONE STAGE 2 MANAGER INFORMS LOCAL UNIVERSITY CAMPUS TEAM LOCAL CAMPUS TEAM MANAGER INFORMATION PURPOSES ONLY MANAGER INFORMS CONTRACTS PROJECT MANAGER UNIVERSITY PROJECT MANAGER RESPONSIBLE FOR THE PROJECT WORKS INSTRUCTED BY CAMPUS TEAM ONLY CONTACTS THE SAFETY AND COMPLIANCE OFFICER ASAP BY PHONE PROJECT WORKS STAGE 2 17

21 APPENDIX A EMERGENCY RESPONSE FLOW CHART EMERGENCY RESPONSE STAGE 2 SAFETY AND COMPLIANCE OFFICER COMPLETES INCIDENT REPORT FORM AND SENDS TO H&S ADVISOR SAFETY AND COMPLIANCE OFFICER VISITS SITE TO CHECK LOCK DOWN STATUS SAFETY AND COMPLIANCE OFFICER INSTRUCTS LOCK DOWN NO DOES IT COMPLY? YES IS IT IN THE ASBESTOS REGISTER? IN THE ASBESTOS REGISTER ACM NAD NOT IN ASBESTOS REGISTER MANAGER TO LIAISE WITH ESTATES MANAGER MANAGER TO REPORT INCIDENT AND LIAISE WITH ESTATES MANAGER ESTATES MANAGER TO CONSULT WITH ASBESTOS SURVEYING/LARC/ANALYTICAL CONTRACTOR/SAFETY AND COMPLIANCE OFFICER/MANAGER ANALYTICAL CONTRACTOR TO CONDUCT AIR MONITORING AND PASS RESULT TO ESTATES MANAGER ESTATES MANAGER TO REPORT INCIDENT TO DIRECTOR OF ESTATES PLACED INTO ASBESTOS REGISTER PLANNED REMOVAL ESTATES MANAGER TO CONSULT WITH ASBESTOS SURVEYING/LARC/SAFETY AND COMPLIANCE OFFICER/MANAGER SURVEYING AND ANALYTICAL CONTRACTORS TO CONDUCT AIR MONITORING AND BULK SAMPLING PASS RESULT TO ESTATES MANAGER ACM IDENTIFIED LARC/ANALYTICAL CONTRACTOR EMERGENCY CLEAN UP PROCESS FINAL UPDATE OF ASBESTOS REGISTER AC/LARC EMERGENCY CLEAN UP PROCESS 18

22 APPENDIX B PROJECT WORKS FLOW CHART PROJECT WORKS STAGE 1 UNIVERSITY ESTATES MANAGER/PROJECT MANAGER NOT CONSULTANTS SCOPE OF WORKS INCLUDING SERVICE AND CONTRACTOR TRANSIT ROUTES CONSULT SAFETY AND COMPLIANCE OFFICER AND ASBESTOS REGISTER TO OBTAIN ASBESTOS HISTORY OF THE AREA CONTACT ASBESTOS SURVEYING COMPANY PASS ON SCOPE OF WORKS/PLANS AND ARRANGE/ATTEND SITE VISIT TO DISCUSS SCOPE OF WORKS. ( ASBESTOS SURVEYING COMPANY PREPARES & PROVIDES WRITTEN SURVEY BRIEF AND QUOTE TO ESTATES MANAGER ESTATES MANAGER TO REVIEW SURVEY BRIEF AND QUOTE OK NOT OK DISCUSS WITH AC ESTATES MANAGER ACCEPTS AND INSTRUCTS WORKS ASBESTOS SURVEY CARRIED OUT ESTATES MANAGER SENDS COPY TO MAINTENANCE/PROJECT MANAGERS NOT OK DISCUSS WITH AC NAD NO SAFETY AND COMPLIANCE OFFICER TO REVIEW ASBESTOS REPORT YES ASBESTOS REGISTER UPDATED BY SAFETY AND COMPLIANCE OFFICER SAFETY AND COMPLIANCE OFFICER INSTRUCTS WORKS TO PROCEED WITH CAUTION OK SIGN OFF ACM PRESENT? STAGE 2 IF THE SCOPE OF WORKS CHANGES AT ANY TIME THE MANAGER MUST RETURN TO BEGINNING OF STAGE 1 19

23 APPENDIX B PROJECT WORKS FLOW CHART PROJECT WORKS STAGE 2 (ACMs IDENTIFIED) ACM IS IDENTIFIED IN THE SURVEY NOT OK DISCUSS WITH AC ESTATES MANAGER TO LIAISE WITH SAFETY AND COMPLIANCE OFFICER AND REQUEST TENDER SPECIFICATION FOR REMOVAL SAFETY AND COMPLIANCE OFFICER TO PRODUCE TENDER SPECIFICATION FOR REMOVAL ESTATES MANAGER TO REVIEW OK SPECIFICATION OK ESTATES MANAGER SENDS COPY TO MAINTENANCE/PROJECT MANAGERS LARC ISSUE QUOTES FOR THE REMOVAL WORKS ESTATES MANAGER ISSUES INSTRUCTION FOR REMOVAL TO LARC LARC SUMBIT RAMS NOT OK DISCUSS WITH LARC ESTATES MANAGER COPIES RAMS TO PRINCIPAL DESIGNER IF APPLICABLE OK SAFETY AND COMPLIANCE OFFICER REVIEW AND ACCEPTANCE OF RAMS COPYING TO ESTATES MANAGER PROCEED WITH REMOVALS COMPLETION OF REMOVAL WORKS SAFETY AND COMPLIANCE OFFICER UPDATES ASBESTOS REGISTER IF THE SCOPE OF WORKS CHANGES AT ANY TIME THE MANAGER MUST RETURN TO BEGINNING OF STAGE 1 20

24 APPENDIX C MAINTENANCE AND REACTIVE WORKS FLOW CHART TRADES TEAM TRADE TEAM TO CHECK LOCATION OF WORK AGAINST THE ASBESTOS REGISTER TRADE TEAM SIGNS VERIFICATION FORM NO ACMs PRESENT IN LOCATION? YES WORKS PROCEED WITH CAUTION TRADE TEAM SIGNS VERIFICATION FORM AND VISITS SITE STATUS OF ACMs? ACMs IN POOR CONDITION/DAMAGED? YES TRADE TEAM TO LIAISE WITH MAINTENANCE MANAGER NO WORK TO START YES ARE ACMs LIKELY TO BE DISTURBED OR DAMAGED BY WORK? NO MAINTENANCE MANAGER TO LIAISE WITH ASBESTOS REMOVAL CONTRACTOR TO CARRY OUT WORKS NO WORKS PROCEED WITH CAUTION FOLLOW APPENDIX B STAGE 2 WORKS PROCEED WITH CAUTION 21

25 APPENDIX D DEFINITION OF CONSTRUCTION WORK Preparation for a Structure Work activities Prefabricated elements of a structure Removal of a structure Installation, commissioning, maintenance, repair and removal of: Site clearance Construction Assembly Decommissioning Mechanical Exploration Alteration Disassembly Demolition Electrical Investigations Excavation including earthwork, trench, well, shaft, tunnel or underground working. Conversion Fitting out Commissioning Renovation Removal of any waste or product resulting from structure during the above. Dismantling Any waste or product resulting from structure during the above. Gas Compressed air Hydraulic Telecommunications Repair Upkeep Computer or similar services which are normally fixed within or to a structure. Redecoration Maintenance Cleaning with water or abrasive at high pressure or using corrosive or toxic substances. Installation of services or cables (refer also to Column 4) 22

26 APPENDIX E VERIFICATION FORM The asbestos register must be checked for all areas where work will be carried out. All details to be entered in columns 1-6 by the Contractor. (1) Date (2) Name (Please print) (3) Company (4) Location of Work Signature (list of areas) (5) Nature of Work (6) Signature of Responsible Person 23